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Credit Bureau Reports Without Written Permission

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Can you take applications for loans over the phone and pull credit? If the customer never comes in and the request is denied, what do you do with the application that has not been signed by the customer that gives you permission to pull credit?

The Fair Credit Reporting Act does not require written permission to access a credit report. Your loan policy may and you wouldn't want to violate that either, but it isn't an FCRA violation.

I suggest telephone applications be dated, time-stamped and denote who took the application and that it was by phone. This provides you an audit trail.

Reg. B revisions which became mandatory April 15, 2004, also require that you have a solid procedure to denote "joint intent" on joint applications. If you revise your telephone procedures, be sure to include this.

First published on 10/4/04

First published on 10/04/2004

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